Boechler, P.C. v. Commissioner of Internal Revenue

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Supreme Court of the United States
Boechler, P.C. v. Commissioner of Internal Revenue
Term: 2021
Important Dates
Argued: January 12, 2022
Decided: April 21, 2022
Outcome
Reversed and remanded
Vote
9-0
Majority
Amy Coney Barrett • Chief Justice John Roberts • Clarence Thomas • Stephen Breyer • Samuel Alito • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Brett Kavanaugh

Boechler, P.C. v. Commissioner of Internal Revenue is a case that was decided by the Supreme Court of the United States on April 21, 2022, during the court's October 2021-2022 term. The case was argued before the court on January 12, 2022.

The court reversed the decision of the United States Court of Appeals for the 8th Circuit in a unanimous ruling, holding the Internal Revenue Code's 30-day time limit to file a petition for review is subject to equitable tolling. Justice Amy Coney Barrett delivered the majority opinion of the court.[1] Click here for more information about the ruling.

HIGHLIGHTS
  • The issue: The case concerned the time limit to file petitions with the United States Tax Court to review Internal Revenue Service (IRS) determinations. Click here to learn more about the case's background.
  • The questions presented: "Section 6330(d)(1) of the Internal Revenue Code establishes a 30-day time limit to file a petition for review in the Tax Court of a notice of determination from the Commissioner of Internal Revenue. 26 U.S.C. § 6330(d)(1). The question presented is:


    Whether the time limit in Section 6330(d)(1) is a jurisdictional requirement or a claim-processing rule subject to equitable tolling."[2]

  • The outcome: The court reversed the decision of the United States Court of Appeals for the 8th Circuit in a unanimous ruling, holding the Internal Revenue Code's 30-day time limit to file a petition for review is subject to equitable tolling. Justice Amy Coney Barrett delivered the majority opinion of the court.[1]


    • The case came on a writ of certiorari to the United States Court of Appeals for the 8th Circuit. To review the lower court's opinion, click here.[3]

    Timeline

    The following timeline details key events in this case:

    • April 21, 2022: The U.S. Supreme Court reversed the U.S. Court of Appeals for the 8th Circuit's ruling and remanded the case.
    • January 12, 2022: The U.S. Supreme Court heard oral argument.
    • September 30, 2021: The U.S. Supreme Court agreed to hear the case.
    • April 16, 2021: Boechler, P.C. appealed to the U.S. Supreme Court.
    • July 24, 2020: The 8th Circuit affirmed the United States Tax Court's dismissal of Boechler, P.C.'s petition for review of the Commissioner of Internal Revenue's determination, holding that the petition was not filed in a timely manner.[3]

    Background

    Boechler, P.C. ("Boechler") is a personal injury law firm based in Fargo, North Dakota. On June 5, 2015, the Internal Revenue Service (IRS) notified Boechler of a discrepancy between prior tax document submissions. Boechler did not respond. The IRS applied a 10% penalty for the lack of response. Boechler did not pay the fine. The IRS notified Boechler of its intent to levy, setting out conditions to collect outstanding debts related to the tax penalty. Boechler requested a Collection Due Process (CDP) hearing but did not establish why it should be relieved of penalties related to the original discrepancy or the unpaid fine. On July 28, 2017, the IRS Independent Office of Appeals sent a determination notice to Boechler upholding the levy, delivered on July 31. According to the notice, there was a 30-day filing deadline for Boechler to submit a CDP hearing petition. Boechler mailed the petition on August 29, 2017, the day after the deadline elapsed.[3]

    The United States Tax Court received Boechler's petition. In court, the IRS moved to dismiss the case, citing a lack of jurisdiction. Boechler argued that the 30-day deadline was not related to the court's jurisdiction, the time limit should be tolled equitably, and that the IRS' calculation of the time limit from the issuance of the determination notice, rather than the date of receipt, violated due process. The Tax Court dismissed Boechler's petition for a lack of jurisdiction since the petition was filed after the deadline expired.[3]

    On appeal to the United States Court of Appeals for the 8th Circuit, the court affirmed the U.S. Tax Court's dismissal of the case.[3]

    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    “ Section 6330(d)(1) of the Internal Revenue Code establishes a 30-day time limit to file a petition for review in the Tax Court of a notice of determination from the Commissioner of Internal Revenue. 26 U.S.C. § 6330(d)(1). The question presented is:


    Whether the time limit in Section 6330(d)(1) is a jurisdictional requirement or a claim-processing rule subject to equitable tolling.[4]

    		”

    Oral argument

    Audio

    Audio of oral argument:[5]



    Transcript

    Transcript of oral argument:[6]

    Outcome

    In a unanimous opinion, the court reversed the judgment of the United States Court of Appeals for the 8th Circuit, holding the Internal Revenue Code's 30-day time limit to file a petition for review is subject to equitable tolling. Justice Barrett delivered the opinion of the court.[1]

    Opinion

    In the court's majority opinion, Justice Barrett wrote:[1]

    “

    Jurisdictional requirements cannot be waived or forfeited, must be raised by courts sua sponte, and, as relevant to this case, do not allow for equitable exceptions. ... To that end, we treat a procedural requirement as jurisdictional only if Congress “clearly states” that it is. ... This case therefore turns on whether Congress has clearly stated that §6330(d)(1)’s deadline to petition for review of a collection due process determination is jurisdictional. ... Section 6330(d)(1) does not expressly prohibit equitable tolling, and its short, 30-day time limit is directed at the taxpayer, not the court. ... None of this is to say that Boechler is entitled to equitable tolling on the facts of this case. That should be determined on remand. We simply hold that §6330(d)(1)’s filing deadline, like most others, can be equitably tolled in appropriate cases.[4]

    		”
    —Justice Amy Coney Barrett

    Text of the opinion

    Read the full opinion here.

    October term 2021-2022

    See also: Supreme Court cases, October term 2021-2022

    The Supreme Court began hearing cases for the term on October 4, 2021. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[7]

    The court agreed to hear 68 cases during its 2021-2022 term.[8] Four cases were dismissed and one case was removed from the argument calendar.[9]

    The court issued decisions in 66 cases during its 2021-2022 term. Three cases were decided without argument. Between 2007 and 2021, SCOTUS released opinions in 1,128 cases, averaging 75 cases per year.


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 Supreme Court of the United States, Boechler, P.C. v. Commissioner of Internal Revenue, decided April 21, 2022
    2. ↑ 2.0 2.1 U.S. Supreme Court, "20-1472 BOECHLER, P.C. V. CIR, QUESTION PRESENTED:," accessed September 30, 2021
    3. ↑ 3.0 3.1 3.2 3.3 3.4 U.S. Court of Appeals for the 8th Circuit, Boechler, P.C. v. Comm'r, decided July 24, 2020
    4. ↑ 4.0 4.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    5. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued January 12, 2022
    6. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued January 12, 2022
    7. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed February 4, 2021
    8. ↑ Consolidated cases are counted as one case for purposes of this number.
    9. ↑ U.S. Supreme Court, "Order List: 593 U.S.," May 17, 2021
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